On March 17, 2016 a
Motion-Secondary
was filed
involving a dispute between
Baker Hughes Oilfield Operations Incorporated,
and
Pina, Michelle Lee,
for OTHER CIVIL
in the District Court of Harris County.
Preview
CAUSE NO. 2016 17256
BAKER HUGHES OILFIELD IN THE DISTRICT COURT OF
OPERATIONS, INCORPORATED,
Plaintiff
HARRIS COUNTY, TEXAS
MICHELLE LEE PINA
Defendant JUDICIAL DISTRICT
DEFENDANT’S OBJECTIONS TO UNSWORN
DECLARATION OF GUY MCCUNE
Defendant presents the following objections to certain testimony from Plaintiff’s witness Guy
McCune and attached to Plaintiff’s petition:
Paragraph last sentence, Objections: Conclusionary, speculative and lack of personal
knowledge/hearsay. Plaintiff’s witness does not know what was in the subject emails, and provides no
basis or factual evidence of harm allegedly sustained by Plaintiff.
Defendant respectfully requests the Court to sustain these objections.
Respectfully submitted,
BUCK KEENAN LLP
/s/ Grant P. Harpold
GRANT P. HARPOLD
State Bar No. 09034300
2229 San Felipe, Suite 1000
Houston, Texas 77019
gharpold@buckkeenan.com
4500 Telephone
(713) 225 3719 Facsimile
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has been
forwarded to all known counsel of record in this cause in accordance with the Texas Rules of
Civil Procedure on this the 2nd day of June, 2016.
Ms. Linda C. Schoonmaker
Seyfarth Shaw, LLP
700 Milam Street, Ste. 1400
Houston, Texas 77002
lschoonmaker@seyfarth.com
Counsel for Plaintiff
By electronic mail
/s/ Grant P. Harpold
Grant P. Harpold
Document Filed Date
June 02, 2016
Case Filing Date
March 17, 2016
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
CAUSE NO. 2016 17256 BAKER HUGHES OILFIELD IN THE DISTRICT COURT OF OPERATIONS, INCORPORATED, Plaintiff HARRIS COUNTY, TEXAS MICHELLE LEE PINA Defendant JUDICIAL DISTRICT DEFENDANT’S OBJECTIONS TO UNSWORN DECLARATION OF GUY MCCUNE Defendant presents the following objections to certain testimony from Plaintiff’s witness Guy McCune and attached to Plaintiff’s petition: Paragraph last sentence, Objections: Conclusionary, speculative and lack of personal knowledge/hearsay. Plaintiff’s witness does not know what was in the subject emails, and provides no basis or factual evidence of harm allegedly sustained by Plaintiff. Defendant respectfully requests the Court to sustain these objections. Respectfully submitted, BUCK KEENAN LLP /s/ Grant P. Harpold GRANT P. HARPOLD State Bar No. 09034300 2229 San Felipe, Suite 1000 Houston, Texas 77019 gharpold@buckkeenan.com 4500 Telephone (713) 225 3719 Facsimile CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been forwarded to all known counsel of record in this cause in accordance with the Texas Rules of Civil Procedure on this the 2nd day of June, 2016. Ms. Linda C. Schoonmaker Seyfarth Shaw, LLP 700 Milam Street, Ste. 1400 Houston, Texas 77002 lschoonmaker@seyfarth.com Counsel for Plaintiff By electronic mail /s/ Grant P. Harpold Grant P. Harpold